Memorandum submitted by the Centre for
Business Relationships, Accountability, Sustainability and Society
(BRASS)
EXECUTIVE SUMMARY
For the new UK Waste Strategy to improve waste
management and anticipate coming EU legislation, it must adopt
a long-term vision and be pro-active towards waste issues. The
points below identify some of the main issues and actions we believe
are key to ensuring that such future objectives are met.
Key Issues
— There has been little focus on the
waste hierarchy in the UK to date.
— There appears to be a perception
that there is a quick fix solution to waste disposal problems
which is far from reality.
— Regulation to date has tended to
focus on end of pipe. New innovative approaches are needed to
address issues upstream where waste is generated.
— There is a fundamental lack of integration
and coherency between organisations and between actions that characterise
waste management in the UK.
— There is no real national infrastructure
that is designed to efficiently deal with any one waste stream
to ensure recycling or minimisation are addressed in the most
effective and efficient way.
— Current support and initiatives tend
to operate independently of each other.
— The biggest waste problem appears
to be that of commercial and industrial wastes generated by SMEs.
— There is a lack of attention to design
issues that could do much to reduce the initial generation of
waste.
— There is relatively poor measurement
of waste volumes and types especially concerning SME waste.
— There is a lack of strategic thinking
about national scale integrated investment for diversion of wastes
from landfill into the materials and resource supply streams.
— Design of products (and services)
is a key area for investment if the government truly wishes to
reduce wastes from first principles.
— Incineration is unlikely to ever
be a realistic option either from the health aspect or from the
point of view of public perceptions of risk.
— Ensuring sustainability issues are
the bedrock of waste management requires a wholesale cultural
change in individuals, households, businesses, public bodies and
others.
— Cultural change can be supported
by much more comprehensive awareness raising and information on
waste management practices and options.
— People need to be convinced of the
benefit to them if they are to be really committed to undertaking
sustainable waste management practices.
— Future waste strategy needs to be
co-ordinated, strategic, coherent and well supported.
Introduction of new policy instruments to promote
sustainable waste management
— Combining market-based with regulatory
instruments for both industry and consumers.
— Creating incentives to ensure that
material recovery becomes the most competitive solution for waste
management.
— Promoting eco-design by introducing
a national reward scheme.
— Consider introducing reduced VAT
on eco-labelled products.
— Increase landfill tax level.
Development of an integrated and coherent approach
— The UK Government should include
clear waste minimisation targets to ensure that the waste hierarchy
works at its best and that sustainable treatment methods prevail
upon less environmentally friendly ones.
— Co-ordinate recycling initiatives
amongst cities and regions and mainstream best practice projects
in order to create markets for recyclates on a long-term basis.
Promoting change across the board
— Adopt a systematic approach to waste
management throughout the public sector so that it becomes a leader
in sustainable waste management.
— Integrate and disseminate good environmental
practices across the board (eg green procurement should become
the norm).
— Promote eco-design, re-use, take-back
and refurbishment schemes in business and strengthen markets for
the secondary use of certain waste types.
— Improve data collection and measurement
methods.
— Raise awareness about options for
municipal waste treatment methods.
— Develop a more comprehensive information
campaign for householders.
— Promote green purchasing and sustainable
practices at the level of the household.
Financial Incentives
— The UK government needs to address
waste management issues by thinking in a far more strategic and
long term way. It needs to be radical and imaginative in its thinking
and should be more creative in the use of the funds it has at
its disposal in supporting initiatives that will solve some of
the problems identified above.
— To ensure coherency in taxation,
create an energy from waste tax, and as suggested in the waste
strategy for Wales Wise About Waste, withdraw the current exemption
from the Climate Change Levy for energy from waste incineration
of mixed wastes.
— Increase funding available to local
authorities to promote household reward schemes for sustainable
waste practices (some best practice initiatives adopted in other
EU countries are easily transferable).
— Consider introducing household waste
collection tax.
SUBMISSION DETAIL
We understand that the Committee is undertaking
an investigation as to how we might move forward in the future
to promote innovative solutions to waste management, and further
options higher up the waste hierarchy as set out in the Waste
Framework Directive. One immediate comment is that the UK has
hardly focussed on a waste hierarchy to date. This is because
with such a high proportion of waste continuing to go to landfill,
most attention has been given to climbing up from the bottom (landfill)
rung of the ladder, with little attention to how high we should
climb from there. Indeed, the time devoted by the UK in negotiating
with the European Union the inclusion of incineration as a recovery
option is indicative of this. We seem still to hope that there
will be a quick fix solution to save us from the mess in which
we find ourselves.
The Regulatory System
We need to know much more about regulatory responses
in the face of recurrent increases in waste arisings. Regulation
often focuses on the end of pipe. Although the duty of care in
relation to waste spreads through the waste chain, this is a most
basic approach to ensuring environmental protection once waste
is produced. Waste licensing tends to focus on those handling
waste once discarded. Relatively little attention is given through
the regulatory system to waste producers. Of late, there have
been financial incentives, such as landfill tax and producer responsibility
initiatives. However, it is not clear that these are set at an
optimal level to change behaviour, they again tend to bite more
strongly with bigger industry, and often they are too remote from
large numbers of waste producers to make any difference.
Integration
One of the weaknesses that characterises waste
management in the UK as compared to that pursued in other countries
such as Sweden, is the lack of integration between approaches
to waste management, bodies responsible for waste management and
connectivity along the supply chain and life cycle of materials
that turn into wastes. This lack of integration not only hinders
the development of efficient management of wastes at each stage
in its lifecycle but can cause points of hindrance to programmes
and initiatives which show promise in achieving progress. There
is little connection or communication, for example, between those
organisations aiming to support businesses, or indeed householders,
in moving towards waste minimisation practices, and those organisations
charged with dealing with waste disposal in one form or another.
This lack of communication may occur even when different departments
within one organisation are involved. Integration also does not
appear to have been much developed in relation to the technical
and market management of wastes. Most waste streams appear to
be treated, researched and to some extent, administered, separately.
Thus, different types of wastes whilst being segregated for recycling
are perhaps not considered in a more imaginative or innovative
way in terms of potential for reuse. It is necessary to consider
how different waste streams may be combined at some point in the
downstream supply chain to achieve most efficient value extraction
and re-entry into the materials supply chain or as reuse opportunities.
Integration also extends to ensuring that procurement practices
in public bodies and purchasing by businesses and even householders
are changed to reflect the demands of sustainability and resource
efficiency.
Infrastructure
One of the greatest weaknesses besetting waste
management in the UK, and causing some of the most difficult problems
in achieving a move up the waste hierarchy is the lack of national
infrastructures to deal with waste issues. The UK appears to be
typified by the "ad-hoc approach" or "individualistic"
approach. While some structures exist for some aspects of waste
management, ie waste licensing, packaging waste regulation by
the Environment Agency, there is a multiplicity of approaches
taken by Local Authorities in the ways they deal with waste. While
pilot projects and limited spatial application programmes can
achieve admirable outputs, they are not supported sufficiently
by government to achieve active roll out across the whole of the
country. As a result, a visit to any number of local authorities
is likely to show a similar number of different approaches. There
is an element of reinventing the wheel that uses resources that
could be more effectively targeted elsewhere. The time for pilot
projects in relation to a number of aspects of waste is surely
past. Home composting, for example, although the subject of some
debate regarding the specification and composition of end materials,
is generally accepted as a sensible way for households to deal
with their organic waste, either on an individual basis, or within
small community schemes. Despite efforts on the part of a wide
range of organisations including the Soil Association, the Composting
Association and others, composting remains a patchy activity with
few clear objectives and directions or support from central government.
The statutory duty of Local Authorities to manage their wastes
has encouraged them to address the composting issue, but they
may be far more effective working within a clearly defined, resourced
and UK wide framework and structure.
Key Waste Streams—The Case of Commercial
and Industrial Waste
The same is the case for much industrial and
commercial waste. Projects and pilot studies proliferate, all
offering good ideas and useful outputs, but duplication is inevitable.
Central direction and structure could assist these efforts to
become more co-ordinated, and eventually more economically effective.
This is particularly true in response to new markets for recyclates,
whereby pilot studies may be seen to achieve a high level of market
potential, but lack the capacity or access to national structures
to organise those markets and the logistical management of transfer
of wastes from point of generation to point of recycling in any
coherent way. There are such a large number of waste streams where
this pattern is repeated that it only be regarded as a demonstration
of inefficiency. One lesson that might be learnt is to respond
to public perceptions about different waste disposal options.
Rather than looking from the bottom rung of the waste hierarchy
up the ladder, it may help to start at the top of the ladder downwards.
Commercial and industrial waste, measured at least by its tonnage,
presents the largest problem. In terms of waste prevention and
waste minimisation, there are no shortage of initiatives, but
these are often tailored specifically for the firm and sometimes
for the site. They tend to reside within the bigger and better
run companies. In the meantime, small and medium enterprises (SMEs)
continue to generate huge quantities of waste untouched by in-built
economic incentives towards waste minimisation. There are some
very obvious things to say about this. The first is that design
and process issues are key to any approach to waste prevention
and waste minimisation, yet these are rarely given significant
attention in discussions about waste. The second issue is that
measurement is important. We need to know more about waste streams
and SMEs must have much greater realisation about inputs and outputs
in the production process. In short, they need to subject their
activities to continuing measurement based on mass balance approaches.
Investment
The UK has only recently woken up to the need
for investment on a large scale into the management of waste.
Thinking and investment needs to be strategic. Markets for recyclates
cannot be easily developed, and the government needs to consider
whether market intervention in the form of subsidy is an appropriate
measure to take. This is especially true of relatively low value,
high volume wastes currently entering landfill sites.
The investment currently taking place into the
research and development aspects of waste management, for example,
through the WRAP initiative, is to be applauded, but even here
the investment needs to be more clearly capitalised on. Research
and development projects, best practice programmes and educational
and awareness raising initiatives need, once proved, to be supported
at a much grander scale and to be rolled out across the UK. This
needs to be achieved within relatively short time frames if targets
from Europe are to be met, but also has to be developed with strategic
objectives in mind, and not just those that relate specifically
to diversion of waste from landfill sites. The sustainable economic
case for integrated waste management on a large scale should be
paramount. The resource implications for British industry should
form a key focus for those in the policy arena and the waste management
sector. Long term diversion of materials from landfill into recycling
and into the materials supply stream should be looked on as a
potentially major resource, and supported as such by government.
Waste minimisation and the reduction of imports should be an economic
target. The support of a wide range of small and medium sized
companies designed to deal with wastes through recycling and reprocessing,
either as independent companies, or linked to large waste suppliers,
Local Authorities, or as part of eco-industrial parks should be
a major focus of support. Such companies would, if properly supported,
reduce the waste volumes currently entering landfill, provide
employment, generate new products and support the UK, and specifically
some ailing regional economies.
Waste Disposal Options—The Case of Incineration
As time goes by it becomes more and more clear
that incineration with or without energy recovery (the next rungs
on the ladder) will not provide a quick fix solution. The fact
that it can take a city like Southampton 12 years to introduce
a municipal waste incinerator tells us that, whatever the public
may favour as alternative solutions to waste management, incineration
does not have significant support. This is not to enter into arguments
concerning the utility or human health considerations of incineration.
It is simply to record important public perceptions that militate
against incineration options and which do not seem to abate over
time.
Proactive and Preventive Action—Education
and Cultural Change
Awareness raising, education and cultural change
on a UK wide scale should be part of the integrated approach.
Individuals, households and businesses are only likely to change
their waste management behaviours over a long period of time and
high profile political commitment and investment is paramount
if waste issues are to be taken seriously. People need to be convinced
of the benefit to themselves, and to the country, in the medium
to long term if such behavioural changes are to be made. However,
encouraging such change without ensuring the development of effective
logistical and administrative frameworks to deal with waste, and
without developing the markets for waste derived products, be
they recycled or reused products, is bound to result in lack of
belief and disaffection with the system. People need to be properly
informed about the options for waste disposal and waste management
in the home or business. Currently such information tends to be
rather superficial and lacks sufficient spatial coverage. Again,
integration, but at a national scale with clearly defined intervention
and resource support where necessary is vital.
CONCLUSIONS
Although we would favour more money from the
landfill tax system devoted to environmental improvement generally,
of late there has been money to pursue initiatives to cope with
particular waste streams. There has been no shortage of research
(although this is now threatened because of changes to landfill
tax credits) but there seems to be significant problems in following
research through into practical applications. In short, there
seems to be a lack of co-ordinated management that takes approaches
which have been shown to work effectively, and invests in these,
supporting the initiatives while markets for recycled goods are
developed. Initiatives must also be given time to work. It will
take considerable time, possibly even generations to change attitudes
towards waste, while often approaches are abandoned if they are
not delivering quick fix solutions. We hope that the Committee's
approach will genuinely look to the future, and will help promote
co-ordinated, well managed and longer term approaches to both
waste minimisation and to the effective construction of solutions
to problem waste streams.
Centre for Business Relationships, Accountability,
Sustainability and Society
23 January 2003
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